***CMS has released the 2027 changes to remote care management. Learn how to keep your RPM program compliant with the new rules. Register for our complimentary, expert-led webinar, "Understanding Medicare's 2027 Changes to Remote Care Management," on November 19, 2026, at 2:00 PM ET / 11:00 AM PT. Reserve your seat here → ***
The CY 2027 Physician Fee Schedule is final, and remote patient monitoring (RPM) programs have a clearer picture of the year ahead. Some of the changes are firm. Several of the bigger ones are still effectively being written, and that gives practices time to plan and room to shape the ultimate outcome. Below, I cover the new initiating visit requirement, the direct employee rule that's been delayed to 2029, and where payment rates stand for 2027 and beyond.
The New Requirement: An Initiating Visit
For new patients who start RPM on or after Jan. 1, 2027, RPM must be discussed with the patient at a face-to-face visit before billing begins The visit can be in person or via telehealth, with the billing practitioner or another practitioner of the same specialty at the same clinic. The rule is more flexible than it may sound:
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The visit doesn't need to be about RPM. A routine E/M visit where monitoring comes up qualifies.
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Setup can happen later. The RPM device doesn't need to be supplied or set up at the visit, and CMS set no deadline between the visit and the start of monitoring.
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It's one visit per patient, not per episode. A device change, a clinical change, re-enrollment, or a new billing practitioner within the practice doesn't require another visit.
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Current patients are grandfathered. Anyone already enrolled in an RPM program before Jan. 1, 2027 is covered.
For many practices, all this change will mean is documenting a conversation that’s probably already happening.
Direct-Employee Requirement: On Paper for 2029, Future Unknown
As written, starting Jan. 1, 2029, clinical staff time billed under the treatment management codes (CPT 99457, 99458, and 99470) must come from direct employees of the billing practitioner or practice.
That's what the rule says. However, CMS pushed the policy back two years because it still hasn't decided what the policy actually is. It declined to define "direct employee," said it needs time to specify which staffing arrangements will qualify, and committed to issuing sub-regulatory guidance before 2029. Two more rulemaking cycles (CY 2028 and CY 2029) come first.
Here's what that means for practices that outsource RPM now or plan to:
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Nothing changes in 2027 or 2028. Contracted clinical staff are still permitted under existing incident-to rules.
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The scope is narrow. Even as written, the restriction covers only the clinical time codes. Device supply, logistics, onboarding support, software, connectivity, data hosting, and technical assistance can still come from outside vendors. Nothing in the rule prohibits outside staff from contributing to the services billed under the device codes (CPT 99454 and 99445).
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Other care management codes are unaffected. Chronic care management (CCM) and advanced primary care management (APCM) can still be outsourced. Programs can dual-enroll patients and have outside staff put care management efforts towards CCM or APCM instead of billing the RPM time codes with employed staff when clinically appropriate.
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CMS often revises delayed policies. CMS has a track record of finalizing rules with a delayed start and then rewriting or dropping them before they take effect. I would expect this one to look different by 2029.
In short, outsourced RPM programs can keep running as they do today for at least two more years. That leaves ample time to monitor CMS's guidance, weigh in during the next two rulemaking cycles, and adjust staffing models once the direct-employee rule is finalized (or eliminated).
Valuation: 2027 Is Set, 2028 Is Open
The 2027 reimbursement numbers are a mixed bag. The device codes take the biggest cut after CMS crosswalked them to self-measured blood pressure (SMBP) codes. The treatment management codes held steady because CMS withdrew its proposal to remove the clinical staff time inputs from their practice expense valuation.
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CPT
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Description
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2026 Base Rate
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2027 Base Rate
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From RPM Changes
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From CF Change
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Total Change
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99453
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Initial setup and patient education
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$21.71
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$19.90
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−6.2%
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−2.3%
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−8.3%
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99454
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Device supply, 16–30 days
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$52.11
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$41.11
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−19.2%
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−2.3%
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−21.1%
|
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99445
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Device supply, 2–15 days
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$52.11
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$41.11
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−19.2%
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−2.3%
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−21.1%
|
|
99457
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Treatment management, first 20 min
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$51.77
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$50.58
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0.0%
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−2.3%
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−2.3%
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99458
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Treatment management, each additional 20 min
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$41.42
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$40.46
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0.0%
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−2.3%
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−2.3%
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99470
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Treatment management, first 10 min
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$26.05
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$25.45
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0.0%
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−2.3%
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−2.3%
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Rates are estimated national amounts at the non-APM conversion factor. Because CMS has not yet published the final Addendum B, values for the setup and device codes come from the proposed rule’s Addendum B. Values for the treatment management codes come from the CY 2026 Addendum B, since CMS did not finalize its proposal to remove their practice expense inputs. CF = conversion factor.
To put these cuts in context: Across Prevounce’s client base, we saw anecdotally about a 20% increase in RPM program revenue after CMS introduced two new codes in 2026, CPT 99445 and 99470. The 2027 rates will largely reverse those gains and return program revenue to roughly 2025 levels. That's not ideal, but it isn't catastrophic either. The real opportunity is in 2028.
Another device code cut is scheduled for 2028, when the remainder of the phased-in reduction takes effect, but that number isn't set. CMS acknowledged it continues to lack reliable device cost data, and the American Medical Association's (AMA) Relative Value Scale Update Committee (RUC) will review practice expense inputs for all RPM codes in January 2027. CMS is likely to revisit the rates in the CY 2028 rulemaking with the AMA RUC's recommendations in hand. So, the current crosswalk to SMBP codes is unlikely to be the final word.
The Bottom Line
The 2027 changes are set, and they're manageable. Beyond 2027, the most significant provisions, including the staffing rules and the 2028 device rates, are still open, with comment periods and data reviews ahead. Programs that stay informed and engaged will be in the best position to influence how these rules turn out.
For a full breakdown of what CMS finalized, what's still open for 2028 and 2029, and what your RPM program needs to do before the new year, join me while I present our complimentary webinar, “Understanding Medicare's 2027 Changes to Remote Care Management,” on Nov. 19 at 2:00 PM ET / 11:00 AM PT. I will walk through the final rule's RPM and remote care provisions and take your questions. Reserve your seat here, and feel free to share this link with your colleagues.
* Disclaimer: The above information is speculation and we have no internal knowledge of CMS plans. The above is for informational purposes only and does not constitute legal or other professional advice. Billing and coding requirements — especially in the telehealth space — can change and be reinterpreted often. You should always consult an attorney and/or medical billing professional prior to submitting claims for services to ensure that all requirements are met.
